Elizabeth A. Khalil Member

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Commerce Financial Industry Group Bank Regulatory Consumer Financial Services Financial Services Regulatory & Compliance Bar Admissions District of Columbia Massachusetts Michigan New York Education

1 Elizabeth A. Khalil Member Chicago 10 South Wacker Drive Suite 2300 Chicago, IL Areas Of Practice Government Policy & Practice Cannabis Law Privacy and Data Security Industries FinTech, Payments and Digital Commerce Financial Industry Group Bank Regulatory Consumer Financial Services Financial Services Regulatory & Compliance Bar Admissions District of Columbia Massachusetts Michigan New York Education University of Michigan Law School, J.D., 2002 Georgetown University, B.S., cum laude, 1999 Certifications CIPM CIPP/US CIPP/E CAMS T: T2: Elizabeth Anne Khalil is a Member in Dykema s Government Policy Practice Group. She focuses her practice on all aspects of regulatory compliance and risk management for the financial services industry, including consumer protection, privacy/data security, third-party relationships, Bank Secrecy Act/anti-money-laundering (BSA/AML), and the full alphabet soup of federal banking laws and regulations. She is a Certified Information Privacy Manager (CIPM) as certified by the International Association of Privacy Professionals (IAPP) and also holds two additional IAPP certifications: the CIPP/US (US privacy) and CIPP/E (European privacy) credentials. She is also a Certified Anti-Money Laundering Specialist (CAMS) as certified by the Association of Certified Anti-Money Laundering Specialists (ACAMS). Ms. Khalil advises clients on improving their overall compliance management systems and particular compliance programs, including privacy/data security programs, BSA/AML programs, and third-party/ vendor management programs. She also regularly drafts and revises individual policies and procedures within a program. She also provides counsel on permissible bank and bank holding company activities and assistance with corporate applications, including regulatory due diligence in connection with mergers and acquisitions. Ms. Khalil also provides granular subject matter expertise on laws and regulations such as the following: BSA/AML and Office of Foreign Assets Control (OFAC) regulations and policies Privacy and data security laws and regulations, including the Gramm- Leach-Bliley Act (GLBA)/Regulation P, Fair Credit Reporting Act (FCRA), Children s Online Privacy Protection Act (COPPA), the Telephone Consumer Protection Act (TCPA) and CAN-SPAM Act, the General Data Protection Regulation (GDPR), and state data protection and data breach notification laws Unfair or deceptive acts or practices (UDAP) under the Federal Trade Commission Act and unfair, deceptive, or abusive acts or practices (UDAAP) under the Dodd-Frank Act Electronic Fund Transfer Act (EFTA)/Regulation E Truth in Savings Act (TISA)/Regulation DD Expedited Funds Availability Act (EFAA)/Regulation CC Truth in Lending Act (TILA)/Regulation Z

2 Real Estate Settlement Procedures Act (RESPA)/Regulation X Fair lending and other antidiscrimination laws, including the Equal Credit Opportunity Act (ECOA)/Regulation B and Fair Housing Act (FHA) Community Reinvestment Act (CRA) Military Lending Act (MLA) and Servicemembers Civil Relief Act (SCRA) Flood insurance laws and regulations Electronic Signatures in Global and National Commerce Act (E-SIGN) Bank Holding Company Act/Regulation Y Federal Deposit Insurance Act (FDI Act) Ms. Khalil was for many years a federal banking regulator at the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) in Washington, DC. At the OCC, she was an enforcement attorney and specialist in compliance and consumer protection issues. She was a member of numerous interagency teams, including those that wrote regulations implementing the FACT Act amendments to FCRA. At the FDIC, she served as Acting Special Assistant to both the Deputy Director and Director of the FDIC s Division of Depositor and Consumer Protection, helping to oversee the agency s nationwide compliance supervision program and community banking initiatives. She also advised senior FDIC officials on deposit insurance and emerging issues affecting consumers and the banking industry, including virtual currency and mobile financial services. Ms. Khalil also led the interagency team that created the first federal compliance guidance on use of social media by banks and credit unions. Ms. Khalil also served as a senior associate at an AmLaw 100 firm in Washington, DC, where she served in both the Financial Institutions and Privacy practice groups. There, she advised a wide variety of clients including large, complex banks operating worldwide, community banks, and private equity investors on matters including Dodd-Frank Act implementation strategies; enforcement actions; acquisition of banks, including bidding on failing banks marketed by the FDIC; novel uses of consumer data; and enterprise-wide privacy and data security programs. Ms. Khalil is a frequent author and speaker on regulatory matters. She is a contributor to Lexis Practice Advisor and is a member of its advisory board. Seminars & Speeches FinCEN's Beneficial Ownership Rule: New Due Diligence Requirements for Customer Ownership and Control, Webinar, Strafford Publications, Inc. June 26, 2018 CMCP Track: HMDA Compliance Basics, Speaker, Mortgage Bankers Association's Legal Issues & Regulatory Compliance Conference 2018, Los Angeles, California April 29, 2018 Third Party Risk Management, (Interview) Venminder Thought Leadership Series March 7, 2018 The Biometric Information Privacy Act: Litigation Risks and Best Practices for Employers and Others March 7, 2018 The New Successor in Interest Rules: What Mortgage Servicers Need to Know February 27, 2018 Addressing Risks and Regulatory Concerns in Small-Dollar Lending (webinar), Clear Law Institute February 22, 2018 Understanding Legal Constraints to Banking for State-Legal Marijuana Businesses (webinar), Clear Law Institute February 22, 2018 Banking Marijuana Businesses: Is It Just a Pipe Dream?, American Banker Small Business Banking Conference, Austin, TX December 1, 2017

3 Medical Marijuana Out of the Shadows: A New Michigan Industry, Michigan Credit Union League Annual Conference & Exposition, Grand Rapids, Michigan June 8, 2017 Cannabis Law: Banking and Taxation, Panelist, CLE International Michigan Medical Marijuana Conference, Lansing, Michigan April 24, 2017 Enforcement and Liability Issues in Vendor Management (webinar), Panelist, American Banker Vendor Management Boot Camp November 29, 2016 Hot Topics in FinTech and Privacy and Data Security, Moderator, IAPP KnowledgeNet, Chicago, September 28, 2016 Addressing Privacy, Data Security, and Fraud in the Prepaid Card Industry, Chair and Panelist, Washington, DC September 26-27, 2016 Adventures in Vendor Management, Panelist, Texas Association of Bank Counsel Annual Meeting, Austin, TX September 22, 2016 Cybersecurity and Data Privacy Post Dwolla, Panelist, ACI Emerging Payment Systems Forum, Washington, DC September 16, 2016 Adapting to Changing Regulatory, Legislative, and Enforcement Activities, Co-Presenter and Co-Chair, ACI Forum on Cyber Security & Data Privacy and Protection, Chicago, June 23-24, 2016 Privacy & Security 101, Co-Presenter, Pre-Conference Workshop, ACI Cybersecurity and Data Privacy Conference, Chicago, June 23, 2016 Federal and State Government Regulator Panel, Moderator, ACI Cybersecurity and Data Privacy Conference, Chicago, June 23, 2016 The CFPB's Arbitration Rulemaking (webinar), California Bar Business Law Section, Financial Institutions Committee June 14, 2016 The CFPB s Arbitration Rulemaking, California Bar Business Law Section, Financial Institutions Committee June 14, 2016 A Review of Other Recent CFPB Enforcement Actions and Activities, ACI 15th National Forum on Prepaid Card Compliance, San Francisco, California June 2-3, 2016 American Banker Vendor Management Boot Camp (webinar), Presenter May 24-26, 2016 The Eagle Ford Impact: Regional Economic Conditions Affecting Texas Banks, San Antonio, Texas May 18, 2016 Guarding Financial Service Companies and the Law Firms Representing Them Against Risk and Exposure vis-à-vis Cybersecurity and Data Privacy, Panelist, Women Leaders in Financial Services Law and Compliance, New York, New York May 12, 2016 Cybersecurity Regulation for Financial Services, and CFPB Updates Panelist, American Banker Retail Banking Conference, Las Vegas, Nevada April 7, 2016 Chair, Security and Regulatory Track, American Banker Retail Banking Conference, Las Vegas, Nevada April 6-8, 2016

4 Best Practices for Vendor Management, Panelist, American Conference Institute's Advanced Global Legal & Compliance Forum on Cyber Security and Data Privacy & Protection, Washington, D.C. January 29, 2016 Views and Practical Guidance from Speakers from the Federal Government, Panelist, ACI Emerging Payment Systems Conference March 2015 The Evolving Federal Regulatory and Enforcement Waters, Panelist, ACI Prepaid Card Compliance Conference, Chicago, October 2014 The Federal Waters: Perspectives on New and Emerging Payment Systems and the Evolving Federal Regulatory and Enforcement Paradigm, Panelist, ACI Emerging Payment Systems Conference, Washington, DC September 2014 Publications "CFPB Requests for Public Comments Foreshadow Possible Large-Scale Changes" April 10, 2018 "Latest PHH v. CFPB Ruling Brings RESPA and CFPB Enforcement Approaches Back in Focus" February 27, 2018 "Fasten Your Seatbelts: Are You Ready for Another Eventful Year?" January 16, 2018 "The Challenges of Marijuana Banking Just Got Even More Challenging" January 10, 2018 "Federal Law Obstacles to Bank and Credit Union Services for the State-Legal Marijuana Sector" January 2018 The Banking Law Journal Nonbank Money Transmitters, Chapter 3, Co-Author January 2018 Electronic Payment Systems: Law and Emerging Technologies "Nonbank Money Transmitters," chapter contributor December 2017 American Bar Association, Electronic Payment Systems: Law and Emerging Technologies "While CFPB Leadership Fight Continues, Broader Questions Remain About Future of Consumer Financial Regulation," Co- Author November 30, 2017 "What Does the CFPB s Payday Rule Mean for the Future of Small-Dollar Lending?" November 1, 2017 "New CFPB Online Inquiry Form Offers New Way to Ask Regulatory Questions" August 21, 2017 "Outside Bank Directors Take Note: Could Regulators Expectations Be Changing (Again)?" August 16, 2017

5 "Amendments to Regulation CC Affect Liability Considerations for Financial Institutions," Co-Author August 8, 2017 "CFPB Offers Smaller HELOC Lenders Temporary Relief from HMDA Coverage; HMDA Changes Still Loom In the Future," Co-Author July 20, 2017 "Financial Crimes Enforcement Network (FinCEN) s Beneficial Ownership Rule under the Bank Secrecy Act (BSA)," editorial board member and chapter contributor July 2017 Money Laundering, Asset Forfeiture and Recovery and Compliance A Global Guide "Fourth Corner Credit Union Obtains Pyrrhic Victory for Marijuana Banking" June 30, 2017 "Federal Financial Reform: Where Does It Stand?" June 28, 2017 "What Fintech Investors Need To Know About 'Fintech Banks'" May 16, 2017 Law360 "Why 'Compliance by Design' Must Be on Fintech's Roadmap May 16, 2016 Bloomberg BNA Insights CFPB Rule Is Keen On Restricting Arbitration Clauses May 11, 2016 Law360 "Policy Voices: The Data Security Threat in the Mirror" May 5, 2016 Chicagoland Chamber of Commerce "Policy Voices: The Data Security Threat in the Mirror" May 5, 2016 Chicagoland Chamber of Commerce "PLI Financial Institutions Regulation Answer Book", co-author and co-editor October 2014 "Mobile Payments: An Evolving Landscape," co-author Winter 2012 FDIC Supervisory Insights "Bank Anti-Secrecy: U.S. Anti-Money-Laundering Laws and Policies from a Privacy Perspective" 2011 Data Guidance News Khalil and Hickey Set to Present at Mortgage Bankers Association Legal Issues & Regulatory Compliance Conference April 26, 2018 Elizabeth Khalil Talks About Third Party Risk Management with Venminder, Inc. March 7, 2018

6 Elizabeth Khalil s Cannabis Blog Post Republished in Law360 January 22, 2018 Elizabeth Khalil Talks to Bloomberg BNA about Future of Consumer Financial Protection Bureau January 9, 2018 Khalil and Fonté Author Chapters in ABA Treatise on Electronic Payment Systems 2018 Boldrey and Khalil Discuss Banking Issues for Marijuana Industry in Detroit Free Press November 9, 2017 Elizabeth Khalil Examines Federal Reserve s Directives in Compliance Week September 6, 2017 Fonté and Khalil Blog Post Featured in Law360 Expert Analysis Column August 11, 2017 Elizabeth Khalil Discusses Fintech Cases in BloombergBNA Banking Report July 24, 2017 Elizabeth Khalil Comments on Consumer Financial Protection Bureau Actions in Bloomberg BNA: Banking June 2, 2017 Dykema Launches Blog February 27, 2017 Elizabeth Khalil Quoted in BloombergLaw: Banking Article about Changes in Mobile Wallet Regulations October 28, 2016 Elizabeth Khalil Speaks to State Bar of California Business Law Section, Financial Institutions Committee June 15, 2016 Elizabeth Khalil to Serve as Co-Chair for the ACI Forum on Cyber Security & Data Privacy and Protection June 1, 2016 Elizabeth Khalil to Speak at ACI Forum on Prepaid Card Compliance May 27, 2016 Fonté, Khalil and Allen Co-Author Article on FinTech Compliance for Bloomberg BNA s Banking Report May 18, 2016 Elizabeth Khalil and Erin Fonté to Speak at the Windy City Summit May 17, 2016 Elizabeth Khalil to Serve as a Featured Presenter for American Banker Vendor Management Boot Camp May 17, 2016 Elizabeth Khalil Authors Law360 Article on the CFPB s Proposed Arbitration Rule May 12, 2016 Elizabeth Khalil Authors Article on Data Security for Chicagoland Chamber of Commerce May 6, 2016 Elizabeth Khalil Quoted in American Banker May 3, 2016 Elizabeth Khalil to Speak at the ACI Women Leaders in Financial Services Law and Compliance April 13, 2016 Elizabeth Khalil to Speak at the 2016 American Banker Retail Banking Conference March 15, 2016 Elizabeth Khalil to Speak at the ACI Forum on Cyber Security and Data Privacy & Protection January 21, 2016

7 Elizabeth Khalil Authors Article for Chicago Daily Law Bulletin January 20, 2016 Memberships & Involvement International Association of Privacy Professionals (IAPP), Member State Bar Association, Privacy and Information Security Law Section, Member, Federal Communications Bar Association American Bankruptcy Institute Chicago Bar Association

Lawrence D. Kaplan. Washington, D.C. Practice Areas. Admissions. Education. Of Counsel, Corporate Department

Lawrence D. Kaplan. Washington, D.C. Practice Areas. Admissions. Education. Of Counsel, Corporate Department Lawrence D. Kaplan Of Counsel, Corporate Department lawrencekaplan@paulhastings.com Lawrence D. Kaplan is of counsel in the Corporate practice of Paul Hastings and is based in the firm s Washington, D.C.